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					                                    IN THE UNITED STATES DISTRICT COURT
                                  FOR THE WESTERN DISTRICT OF ARKANSAS
                                             EL DORADO DIVISION
      IN RE: PILGRIM’S PRIDE FAIR                                MDL DOCKET No. 1:07-CV-1832
      LABOR STANDARDS ACT LITIGATION
      THIS DOCUMENT RELATES TO:                                  JURY DEMANDED
      All Actions

                                                       NOTICE
To: All persons who are or have been employed by Pilgrim’s Pride Corporation as hourly chicken processing
    workers on or near the line at any time after May 14, 2005.
Re: Lawsuit claiming that Pilgrim’s Pride has failed to pay overtime in violation of federal law.

                                                  1. INTRODUCTION
This Notice informs you of your right to join a lawsuit against Pilgrim’s Pride seeking overtime pay. This Notice
advises you how to participate in this suit, if you choose to do so, and how your rights may be affected by this suit.

                                          2. DESCRIPTION OF THE CASE
The Plaintiffs in this case claim that Pilgrim’s Pride does not pay its hourly chicken processing workers for all the
time they work putting on, taking off and cleaning safety and sanitary equipment, such as smocks, plastic aprons,
ear plugs, safety glasses, hairnets, beard nets, plastic sleeve covers, arm guards, face masks, hard hats, rubber
gloves, cotton liner gloves and metal cutting gloves. The Plaintiffs claim Pilgrim’s Pride has violated the Fair Labor
Standards Act. Pilgrim’s Pride denies that it has violated the law in any respect.
Chicken processing employees who are paid hourly and have worked on or near the line at any of the following
Pilgrim’s Pride facilities are eligible to participate in this lawsuit:
         DeQueen, Arkansas                    Canton, Georgia                        Marshville, North Carolina
         El Dorado, Arkansas                  Dalton, Georgia                        Chattanooga, Tennessee
         Athens, Alabama                      Elberton, Georgia                      Lufkin, Texas
         Enterprise, Alabama                  Gainesville, Georgia                   Mt. Pleasant, Texas
	        Batesville,	Arkansas		               Mayfield,	Kentucky		                   Nacogdoches,	Texas
         Clinton, Arkansas                    Farmerville, Louisiana                 Broadway, Virginia
	        Athens,	Georgia		                    Natchitoches,	Louisiana		              Moorefield,	West	Virginia
The workers who are leading this case, as named plaintiffs, are Stephania Aaron, Alice Shepard, Dorothy Webb,
Cynthia Rayborn, Erica Gresham, Freida Brown, Laronda Carruthers, Reneé Pates, John Chambers, Rose Mary
Porter, LaShedria Traylor, and Melissa Hott (who are called the “Plaintiffs”).

                                     THE LAWYERS REPRESENTING YOU
Do I have a lawyer in this case?
The	Court	ordered	that	several	firms	may	represent	you	and	all	collective	action	members,	including:
Joseph M. Sellers, Plaintiffs’ Lead Counsel                Kelly Tidwell, Plaintiffs’ Liaison Counsel
Jenny R. Yang                                              Patton, Tidwell & Schroeder, L.L.P.
Cohen, Milstein, Hausfeld & Toll, P.L.L.C.,                Texarkana, Texas
Washington, DC 20005
www.cmht.com

Additional lawyers include:
William	S.	Hommel,	Tyler,	TX	•	George	Chandler,	Lufkin,	TX	•	Peter	H.	Burke,	Burke,	Harvey	&	Frankowski,	LLC,	
Birmingham,	AL	•	Robert	Camp,	Cochran	Firm,	PC,	Birmingham,	AL	•	Preyesh	Maniklal,	Maniklal	&	Dennis,	LLP,	
Atlanta,	GA	•	Robert	L.	Salim,	Natchitoches,	LA	•	Philip	R.	Russ,	Jerry	McLaughlin,	Amarillo,	TX	•	A.	Craig	Eiland,	
Galveston,	TX	•	David	Moskowitz,	Richard	Celler,	Morgan	&	Morgan,	Atlanta,	GA		and	Ft.	Lauderdale,	FL	•	Pete	
Winebrake, Dresher, PA.
If you have any questions, or wish to reach any of the Plaintiffs’ lawyers, you may call the toll free number
1-888-816-4995.

                                                         -1-
                                   YOUR RIGHT TO PARTICIPATE IN THIS ACTION
You	have	been	identified	as	a	current	or	former	chicken	processing	worker	at	Pilgrim’s	Pride.		As	such,	you	are	
eligible to join this action by following the instructions below.

                                           3. HOW TO JOIN IN THIS CASE
Enclosed with this Notice is (1) a form entitled: Notice of Consent, and (2) an envelope, postage paid, addressed
to the Notice Administrator. If you decide to join this case, you must complete and sign the Notice of Consent
form and mail it to:
                                                  Notice Administrator
                                                c/o Rust Consulting, Inc.
                                                     P.O. Box 1235
                                              Minneapolis, MN 55440-1235
The	Plaintiffs’	lawyers	will	file	your	Notice	of	Consent	with	the	Court.
YOU MUST RETURN THE NOTICE OF CONSENT BY MAIL WITH A POSTMARK ON OR BEFORE SEPTEMBER
17, 2008. If your completed Notice of Consent is not postmarked on or before that date, you will not be
allowed to join this case.

                               4. THE IMPORTANCE OF ACTING PROMPTLY
The federal law governing this case sets time limits on the right to recover unpaid overtime pay. The time within
which you may participate in this lawsuit will pass, and you may be forever barred from pursuing a claim for unpaid
overtime,	if	you	do	not	complete	the	Notice	of	Consent	and	return	it	to	the	Notice	Administrator,	identified	above,	
with a postmark on or before September 17, 2008.

                                    5. PROTECTION AGAINST RETALIATION
Federal law prohibits Pilgrim’s Pride from retaliating or discriminating against you in any way if you choose to take
part in this case. The Court will not tolerate any such retaliation or discrimination. Federal law also prohibits
Pilgrim’s Pride from pressuring or coercing you not to join this case. If you feel you have been pressured not to
join this case – or retaliated against by Pilgrim’s Pride or one of its employees because you have decided to join
this case – then you should contact the lawyers for the Plaintiffs at the toll free number 1-888-816-4995. Counsel
for Pilgrim’s Pride may not communicate with you directly or indirectly about your claim in this case.

                      6. THE LEGAL EFFECT OF JOINING OR NOT JOINING THIS CASE
If you choose to join this case, you will be bound by any and all rulings by the Court, whether they are favorable
or unfavorable to you. While this suit is proceeding, you may be required to provide information, appear for
deposition, and/or testify in court. Regardless of whether or not you win the case, you will not be required
to pay attorneys’ fees or costs out of your own pocket. The lawyers for the Plaintiffs will be paid only if the
Plaintiffs win or Pilgrim’s Pride settles the case. If that happens, these fees will either be paid by Pilgrim’s Pride,
or paid out of any settlement fund, or both, as the Court directs. Plaintiffs’ counsel will not ask the Court for more
than one-third of your recovery. If there is no recovery, there will be no lawyers’ fee paid to the lawyers.
If you do not join in this case, you may not share in any money damages that the Plaintiffs may win.
If you decide not to join this case, you will not be affected by any Court rulings, favorable or unfavorable, in this
case. You will not receive any money obtained in this case if Plaintiffs win. You are free to consult a lawyer
regarding	whether	or	not	you	can	file	your	own	lawsuit.

                                  7. WHAT ABOUT IMMIGRATION STATUS?
Your immigration status will not be the subject of this lawsuit. You are entitled to seek a recovery regardless of
your immigration status.

                    8. FOR MORE INFORMATION CONTACT PLAINTIFFS’ LAWYERS
If you have any questions about your rights concerning this case, you should contact the Plaintiffs’ lawyers by calling
the toll free number 1-888-816-4995 or by sending an email to the Plaintiffs’ lawyers at overtime@cmht.com.

                       9. NO OPINION EXPRESSED AS TO THE MERITS OF THE CASE
This Notice is issued for the sole purpose of determining who wishes to participate in this case. Although the
Court	has	authorized	the	issuance	of	this	Notice,	the	Court	has	not,	at	this	time,	made	a	determination	as	to	the	
merits of Plaintiffs’ claims or the defenses of Pilgrim’s Pride in this case.
                                                         -2-
     Case 1:07-cv-01832-HFB           Document 21         Filed 07/20/2007       Page 1 of 25



                      IN THE UNITED STATES DISTRICT COURT
                     FOR THE WESTERN DISTRICT OF ARKANSAS
                               EL DORADO DIVISION


IN RE: PILGRIM’S PRIDE                              MDL DOCKET No. 1:07-CV-1832
FAIR LABOR STANDARDS
ACT LITIGATION
THIS DOCUMENT RELATES TO:                           JURY DEMANDED
All Actions



                 CONSOLIDATED COLLECTIVE ACTION COMPLAINT

                                        INTRODUCTION

       1.      Plaintiffs Stephania Aaron, Alice Shepard, Dorothy Webb, Cynthia Rayborn,

Erica Gresham, Freida Brown, Laronda Carruthers, Reneé Pates, John Chambers, Rose Mary

Porter, LaShedria Traylor and Melissa Hott, (hereinafter collectively referred to as “Plaintiffs”)

on behalf of themselves and all others similarly situated, bring this collective action pursuant to

the Fair Labor Standards Act, 29 U.S.C. §201, et seq. (“FLSA”). Plaintiffs are current and

former employees of Pilgrim’s Pride engaged in processing chicken. Plaintiffs allege that

Defendant, Pilgrim’s Pride Corporation (“Pilgrim’s Pride”) has willfully violated Plaintiffs’ right

to receive pay for all time worked and overtime pay for hours worked in excess of 40 per week.

Pursuant to 29 U.S.C. § 216(b), the Plaintiffs also seek to represent all other similarly situated

employees who worked at Pilgrim’s Pride facilities in Arkansas, Alabama, Georgia, Kentucky,

Louisiana, North Carolina, Tennessee, Texas, Virginia, and West Virginia who have not been

appropriately paid for all time worked.

       2.      On May 10, 2007, the Judicial Panel on Multidistrict Litigation (“JPML”) ordered

that, pursuant to 28 U.S.C. § 1407, all related actions brought against Defendant be transferred to

this Court for pretrial proceedings. As the unlawful conduct at issue in these actions are the


____________________________________________________________________________________________
Plaintiffs’ Consolidated Amended Complaint
      Case 1:07-cv-01832-HFB              Document 21     Filed 07/20/2007       Page 2 of 25



same or similar in nature, the named Plaintiffs in each of the actions presently before this Court

have elected to pursue their claims in this Consolidated Amended Complaint.

        3.       The unlawful conduct by Pilgrim’s Pride has been widespread and consistent at its

plants. Despite a ruling by the Supreme Court in Alvarez v. IBP, Inc., 546 U.S. 21 (2005),

holding that employers are obliged to pay employees for all time worked between the first

compensable act of the day and the last compensable act of the day, less bona fide meal breaks,

Pilgrim’s Pride has willfully engaged in the practice of not recording the time for all work

performed and not compensating its employees with appropriate payment for such work.

        4.       Plaintiffs perform tasks at various stages in the process for producing chicken, but

have all been subject to Pilgrim’s Pride’s same illegal policy and practice of willfully failing to

pay workers for all time worked. Plaintiffs bring this action on their own behalf and as

representatives of similarly-situated chicken processing employees. The members of the

proposed class include: all current and former Pilgrim’s Pride employees who have held non-

exempt positions working on or near the chicken processing line in Pilgrim’s Pride’s chicken

processing plants at any time during the period beginning April 20, 2003 through the end of the

notice period, who have not been fully compensated for overtime hours worked. Plaintiffs seek

to represent similarly situated current or former employees from at least 22 Pilgrim’s Pride

facilities including: DeQueen, Arkansas; El Dorado, Arkansas; Athens, Alabama; Enterprise,

Alabama; Batesville, Arkansas; Clinton, Arkansas; Athens, Georgia; Canton, Georgia; Dalton,

Georgia; Elberton, Georgia; Gainesville, Georgia; Mayfield, Kentucky; Farmerville, Louisiana;

Natchitoches, Louisiana; Marshville, North Carolina; Chattanooga, Tennessee; Dallas, Texas;

Lufkin, Texas; Mt. Pleasant, Texas; Nacogdoches, Texas; Broadway, Virginia; and Moorefield,

West Virginia.




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                                                PARTIES

        5.      Plaintiffs are current or former employees of Pilgrim’s Pride’s chicken processing

plants who have held non-exempt positions at some point since April 20, 2003, which is three

years prior to the commencement of the earliest related action that seeks company-wide

collective action certification. Each Plaintiff’s written consent filed in a related action is

attached hereto as Exhibit A. Plaintiffs bring this action on their own behalf and, pursuant to 29

U.S.C. §216(b), as representatives of a proposed collective action of similarly situated

employees.

        6.      Plaintiff Stephania Aaron resides in Arkansas and is a current employee at the

Pilgrim’s Pride El Dorado, Arkansas plant.

        7.       Plaintiff Alice Shepard resides in Arkansas and is a former employee at the

Pilgrim’s Pride El Dorado, Arkansas plant.

        8.      Plaintiff Dorothy Webb resides in Arkansas and is a former employee at the

Pilgrim’s Pride DeQueen, Arkansas plant.

        9.      Plaintiff Cynthia Rayborn resides in Alabama and is a current employee at the

Pilgrim’s Pride Enterprise, Alabama plant.

        10.     Plaintiff Erica Gresham resides in Georgia and is a current employee at the

Pilgrim’s Pride Athens, Georgia plant.

        11.     Plaintiff Freida Brown resides in Georgia and is a current employee at the

Pilgrim’s Pride Elberton, Georgia plant.

        12.     Plaintiff Laronda Carruthers resides in Kentucky and is a current employee at the

Pilgrim’s Pride Mayfield, Kentucky plant.




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        13.     Plaintiff Reneé Pates resides in Louisiana and is a current employee at the

Farmerville, Louisiana plant.

        14.     Plaintiff John Chambers resides in North Carolina and is a former employee at the

Pilgrim’s Pride Marshville, North Carolina plant.

        15.     Plaintiff Rose Mary Porter resides in Tennessee and is a current employee at the

Pilgrim’s Pride Chattanooga, Tennessee plant.

        16.     Plaintiff LaShedria Traylor resides in Texas and is a current employee at the

Pilgrim’s Pride Mt. Pleasant, Texas plant.

        17.     Plaintiff Melissa Hott resides in West Virginia and is a former employee at the

Pilgrim’s Pride Moorefield, West Virginia plant.

        18.     Pilgrim’s Pride is a Delaware corporation with its home office in Pittsburg, Texas

and is authorized to do business in and is doing business in the State of Arkansas.

                                    JURISDICTION AND VENUE

        19.     This court has jurisdiction pursuant to 28 U.S.C. §1331. Venue is proper in the

Western District of Arkansas pursuant to 28 U.S.C. §1391 because a substantial part of the

events or omissions giving rise to the claims have occurred within the Western District and the

El Dorado Division and because the Judicial Panel on Multidistrict Litigation ordered that,

pursuant to 28 U.S.C. § 1407, all related actions brought against Defendant be transferred to this

Court for centralized pretrial proceedings.

                                     GENERAL ALLEGATIONS

        20.     The Plaintiffs and members of the proposed class are or were engaged in

processing chicken at a Pilgrim’s Pride facility. Their work duties include, but are not limited to,

keeping pace with a fast-moving conveyor belt or production line, known as a “chicken




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      Case 1:07-cv-01832-HFB              Document 21     Filed 07/20/2007        Page 5 of 25



processing line,” while they perform assigned tasks on the assembly line, such as slaughtering,

cutting, de-boning, cleaning and packaging or otherwise preparing the chicken for human

consumption. Plaintiffs and members of the proposed class work on or near this processing line,

often moving between different positions within the plant.

        21.      Pilgrim’s Pride requires Plaintiffs and members of the proposed class to arrive at

work before their paid time begins to obtain and put on protective and sanitary equipment and

walk to their place on the chicken processing line. In addition, Pilgrim’s Pride requires Plaintiffs

and members of the proposed class to continue working through part of their unpaid breaks as

they must doff, clean and don this equipment at the beginning and end of each break. Pilgrim’s

Pride also requires workers to take off or doff this equipment, clean it, and store it after their paid

time has ended.

        22.      These actions qualify as compensable work because the donning, cleaning and

doffing of protective and sanitary equipment and gear is required by Pilgrim’s Pride, the United

States Department of Agriculture, or the nature of the job, and as such these activities are integral

and indispensable to the chicken processing work the Plaintiffs and members of the proposed

class perform.

        23.      All Plaintiffs and members of the proposed class use one or more of the following

items of safety and sanitary equipment and gear: a smock, plastic apron, hearing protection,

safety glasses, hairnet, beard net, hard hat or bump cap, plastic sleeve covers, hard plastic arm

guard, rain suit, face mask, rubber gloves, cotton liner gloves and mesh cutting gloves.

        24.      Pilgrim’s Pride provides the employees with the safety and sanitary equipment

that each must wear in order to perform his or her job in a safe and sanitary manner.




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        25.     The system Pilgrim’s Pride uses to record compensable time for Plaintiffs and

members of the proposed class only records as compensable time what is called “line time,”

which limits compensable time to work performed when the chicken processing line is in

operation.

        26.     Pilgrim’s Pride’s line time system does not record all time that Plaintiffs and

members of the proposed class spend donning, doffing, cleaning and sanitizing their safety and

sanitary equipment and gear.

        27.     As a result, Pilgrim’s Pride does not compensate the Plaintiffs and members of the

proposed class for the time they spend donning, doffing, cleaning and sanitizing their safety and

sanitary equipment and gear.

        28.     Pilgrim’s Pride requires Plaintiffs and members of the proposed class to report to

their assigned work stations on the line wearing the required safety and sanitary equipment and

gear by the time the line is scheduled to begin operating.

        29.     Plaintiffs and members of the proposed class must arrive at work before the

beginning of their paid line time to obtain and don the safety and sanitary equipment.

        30.     Prior to beginning their work on the line, employees must first pick up safety and

sanitary equipment from the supply room, walk to their locker room or changing area, don the

gear and walk to their assigned position on the production line. The Plaintiffs and members of

the proposed class are not compensated for the time spent in performing these work activities,

which occur before the chicken processing line begins operation but are integral and

indispensable to Pilgrim’s chicken processing business and related to the principal employment

duties of the chicken processing workers.




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      Case 1:07-cv-01832-HFB              Document 21    Filed 07/20/2007       Page 7 of 25



        31.     Pilgrim’s Pride requires Plaintiffs and members of the proposed class to work

during part of their unpaid meal breaks. Pilgrim’s Pride automatically deducts the full scheduled

break length from their compensated time. During the uncompensated breaks, however,

Plaintiffs and members of the proposed class must doff and clean their safety and sanitary

equipment before eating, walk to stow their equipment, and don and sanitize the safety and

sanitary equipment before returning to their production line. Pilgrim’s Pride does not

compensate them for this work performed during the unpaid breaks.

        32.     At the end of their shift, Plaintiffs and members of the proposed class are required

to remain at the plant performing work after their line time ends. This work includes the removal

or doffing of their safety and sanitary equipment, performing any cleaning that is required and

returning the soiled equipment to their locker or supply room. They are not compensated for any

of these activities.

        33.     The total amount of time daily in which each Plaintiff and member of the

proposed class has been engaged in unpaid work is substantial. This work is compensable as it

occurs after the first compensable act performed each shift by the Plaintiffs and members of the

proposed class and before the last compensable act they perform each shift.

        34.     Pilgrim’s Pride suffers or permits the Plaintiffs and members of the proposed

class to perform this work and denies compensation to them for this work pursuant to an

established policy or practice. As Plaintiffs and members of the proposed class work more than

40 hours per week, Pilgrim’s Pride has been required by law to compensate them for all time

worked over 40 hours per week at one and a half times their regular hourly rate of pay.




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      Case 1:07-cv-01832-HFB              Document 21    Filed 07/20/2007       Page 8 of 25



         35.    Pilgrim’s Pride has willfully failed to pay the Plaintiffs and members of the

proposed class at the rate of one and a half times their regular hourly rate for all time worked in

excess of 40 hours per week, in violation of the FLSA.

                                   INDIVIDUAL ALLEGATIONS
                                            Stephania Aaron

         36.    Plaintiff Stephania Aaron has been employed by Pilgrim’s Pride from October 17,

2002 through the present at the El Dorado, Arkansas plant. She currently works on the 7:30 a.m.

to approximately 4:15 p.m. shift on the line in the pre-pack department. She is a non-exempt

employee.

         37.    To comply with Pilgrim’s Pride’s requirements and to safely perform her job,

Plaintiff Aaron is required to wear safety and sanitary gear and equipment including cotton

gloves, steel gloves, rubber gloves, plastic apron and sleeves, rubber boots, hairnet, and ear

plugs.

         38.    Before reporting to her work station each day, Plaintiff Aaron must obtain and put

on her safety and sanitary gear and equipment, and walk to her place on the line. Plaintiff Aaron

is not compensated for these activities, which were integral and indispensable to Pilgrim’s

Pride’s chicken processing business and related to her principal employment duties.

         39.    Pilgrim’s Pride deducts forty- five (45) minutes from Plaintiffs’ pay each day for

an unpaid lunch break. Pilgrim’s Pride requires Plaintiff Aaron to take off, put on, and clean

items of safety and sanitary gear and equipment during her unpaid lunch break. As a result, she

would not receive her full break, and she was required to perform work during her break for

which she was not compensated.

         40.    After completing her work on the chicken processing line at the end of her shift,

Plaintiff Aaron is required to take off, clean and store her safety and sanitary gear and


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      Case 1:07-cv-01832-HFB              Document 21     Filed 07/20/2007      Page 9 of 25



equipment. Plaintiff Aaron is not compensated for any of these activities, which are integral and

indispensable to Pilgrim’s chicken processing business and related to her principal employment

duties.

          41.   Pilgrim’s Pride requires Plaintiff Aaron to regularly work over forty hours per

week, but Pilgrim’s Pride denied her compensation, either at a regular rate or an overtime

premium, for substantial time she spent donning, doffing and sanitizing protective equipment

each work week.

          42.   Pilgrim’s Pride requires or permits Plaintiff Aaron to don and doff the sanitary

and safety gear or equipment that she uses each workday.

                                              Alice Shepard

          43.   Plaintiff Alice Shepard was employed by Pilgrim’s Pride from November 24,

2003, until June 16, 2005 as a non-exempt employee at the El Dorado, Arkansas plant. Ms.

Shepard most recently worked on the shift from 7:45 a.m. until approximately 4:15 p.m. on the

line in the over-wrap department.

          44.   To comply with Pilgrim’s Pride’s requirements and to safely perform her job, Ms.

Shepard was required to wear various safety and sanitary gear and equipment including cotton

gloves, steel gloves, rubber gloves, plastic apron and sleeves, rubber boots, hairnet, and ear

plugs.

          45.   Before reporting to her work station each day, Ms. Shepard had to obtain and put

on her safety and sanitary gear and equipment, and walk to her place on the line. Plaintiff

Shepard was not compensated for these activities, which were integral and indispensable to

Pilgrim’s Pride’s chicken processing business and related to her principal employment duties.




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        46.     Pilgrim’s Pride deducted forty- five (45) minutes from Plaintiffs’ pay each day for

an unpaid lunch break. Pilgrim’s Pride required that Plaintiff Shepard take off, put on, and clean

items of safety and sanitary gear and equipment during her unpaid lunch break. As a result, she

would not receive her full break, and she was required to perform work during her break for

which she was not compensated.

        47.     After completing her work on the chicken processing line at the end of her shift,

Ms. Shepard was required to take off, clean and store her protective gear and equipment. She

was not compensated for any of these activities, which were integral and indispensable to

Pilgrim’s chicken processing business and related to her principal employment duties.

        48.     Plaintiff Shepard was compensated for approximately forty (40) hours of work

per week. However, she actually works substantial additional overtime hours each week for

which she is not compensated at either her regular rate or at an overtime rate.

        49.     Pilgrim’s Pride required or permitted Plaintiff Shepard to don and doff the

sanitary and safety gear or equipment that she used each workday.

                                             Dorothy Webb

        50.     Plaintiff Dorothy Webb was employed by Pilgrim’s Pride from September 6,

1983 to May 31, 2007 at the DeQueen, Arkansas plant. She worked on the debone line as a non-

exempt employee.

        51.     To comply with Pilgrim’s Pride’s requirements and to safely perform her job,

Plaintiff Webb was required to wear various safety and sanitary gear and equipment including

cotton gloves, rubber gloves, plastic apron and sleeves, rubber boots, hairnet, and ear plugs

Before reporting to her work station each day, Plaintiff Webb had to obtain and put on her safety

and sanitary gear and equipment, and walk to her place on the line. Plaintiff Webb was not




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compensated for these activities, which were integral and indispensable to Pilgrim’s Pride’s

chicken processing business and related to her principal employment duties.

          52.   Pilgrim’s Pride deducted thirty (30) minutes from Ms. Webb’s pay each day for

an unpaid break. Pilgrim’s Pride required Plaintiff Webb to take off items of protective gear and

equipment at the beginning of her unpaid lunch break, clean these items and then put them back

on before the end of the break. As a result, she would not receive her full break, and she was

required to perform considerable work during her break for which she was not compensated.

          53.   After completing her work on the chicken processing line at the end of her shift,

Plaintiff Webb was required to take off, clean and store her protective gear and equipment.

Plaintiff Webb was not compensated for any of these activities, which were integral and

indispensable to Pilgrim’s chicken processing business and related to her principal employment

duties.

          54.   Pilgrim’s Pride required or permitted Plaintiff Webb to don and doff the sanitary

and safety gear or equipment that she used each workday.

                                            Cynthia Rayborn

          55.   Plaintiff Cynthia Rayborn has been employed by Pilgrim’s Pride at the Enterprise,

Alabama facility for twenty-five (25) years, through the present. Her current job is to draw and

trim chicken. She is a non-exempt employee.

          56.   To comply with Pilgrim’s Pride’s requirements and to safely perform her job,

Plaintiff Rayborn must wear safety and sanitary gear and equipment, including a smock, mesh

gloves, plastic arm protector, apron, hairnet, ear protection and footwear.

          57.   Before reporting to her work station each day, Plaintiff Rayborn had to obtain and

put on her safety and sanitary gear and equipment, and walk to her place on the line. Plaintiff




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Rayborn is not compensated for these activities, which are integral and indispensable to

Pilgrim’s Pride’s chicken processing business and related to her principal employment duties.

        58.     Pilgrim’s Pride deducts thirty (30) minutes from Ms. Rayborn’s pay each day for

an unpaid break. During this break, she is required to take off, put on, and clean her protective

gear and equipment. As a result, Ms. Rayborn often has an actual break of significantly less than

30 minutes, as she is required to perform tasks that are integral and indispensable to Pilgrim’s

Pride’s chicken processing business and related to her principal employment duties, for which

she is not compensated.

        59.     After completing her work on the chicken processing line, Plaintiff Rayborn is

required to take off, clean and store her protective gear and equipment. She was not

compensated for any of these activities, which are integral and indispensable to Pilgrim’s Prides’

chicken processing business and related to Ms. Rayborn’s principal employment duties.

        60.     Pilgrim’s Pride has denied Plaintiff Rayborn compensation at either her regular or

overtime rate for a substantial amount of time worked each week in excess of forty (40) hours of

work per week.

        61.     Pilgrim’s Pride requires or permits Plaintiff Rayborn to don and doff the sanitary

and safety gear or equipment that she uses each workday.

                                             Erica Gresham

        62.     Plaintiff Erica Gresham has been employed by Pilgrim’s Pride from August 24,

2004 through the present in the Athens, Georgia plant as a deboner/reworker. Ms. Gresham is a

non-exempt employee.

        63.     To comply with Pilgrim’s Pride requirements and to safely perform her job,

Plaintiff Gresham is required to wear various safety and sanitary gear and equipment including




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cotton gloves, safety gloves, rubber gloves, plastic apron and sleeves, rubber boots, hairnet, and

ear plugs.

        64.     As a deboner/reworker, prior to reporting to her position on the line, Plaintiff

Gresham must obtain her safety equipment from the supply room, put on all protective gear, and

walk to her area on the line. Plaintiff Gresham was not compensated for these activities, which

are integral and indispensable to Pilgrim’s Pride’s chicken processing business and related to her

principal employment duties.

        65.     Pilgrim’s Pride deducts thirty (30) minutes from Plaintiff Gresham’s pay each day

for an unpaid lunch break. Pilgrim’s Pride required Plaintiff Gresham to take off items of

protective gear and equipment at the beginning of her unpaid lunch break, clean these items and

then put them back on before the end of the break. As a result, Ms. Gresham was not permitted

to use the full break period exclusively for personal use, as she was required to perform

considerable work during this break for which she was not compensated.

        66.     After completing her work on the chicken processing line, Plaintiff Gresham is

required to take off, clean and store her protective gear and equipment. Ms. Gresham is not

compensated for any of these activities, which are integral and indispensable to Pilgrim’s

chicken processing business and related to her principal employment duties.

        67.     Pilgrim’s Pride requires Plaintiff Gresham to regularly work over 40 hours per

week, but Pilgrim’s Pride denied her compensation, either at a regular rate or an overtime rate,

for substantial time she spent donning, doffing and sanitizing safety and protective equipment.

        68.     Pilgrim’s Pride requires or permits Plaintiff Gresham to don and doff the sanitary

and safety gear or equipment that she uses each workday.




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                                              Freida Brown

        69.     Plaintiff Freida Brown has been employed by Pilgrim’s Pride since November,

1986 through the present in the Elberton, Georgia Plant. Plaintiff Brown currently rotates shifts

as a QA technician. She is a non-exempt employee who has previously held many other line

positions at the plant.

        70.     In her current position, to comply with Pilgrim’s Pride’s requirements and to

safely perform her job, Ms. Brown is required to wear safety and sanitary gear and equipment,

including a hairnet, plastic apron, plastic sleeve covers, safety glasses, ear plugs, dust mask,

rubber gloves, cotton liner gloves, and a smock.

        71.     Before reporting to her work station each day, Plaintiff Brown has to obtain and

put on her safety and sanitary gear and equipment, and walk to her place on the line. She is not

compensated for these activities, which are integral and indispensable to Pilgrim’s Pride’s

chicken processing business and related to her principal employment duties.

        72.     Pilgrim’s Pride deducts thirty (30) minutes from Ms. Brown’s pay for at least one

unpaid break each day. She is required to take off, put on, and clean her protective gear and

equipment during this break. As a result, Brown spent considerable time during her break

performing tasks that are integral and indispensable to Pilgrim’s Pride’s chicken processing

business and related to her principal employment duties, for which she is not compensated.

        73.     Pilgrim’s Pride has denied Plaintiff Brown compensation at either her regular or

overtime rate for substantial amounts of time worked each week in excess of forty (40) hours of

work per week.

        74.     Pilgrim’s Pride requires or permits Plaintiff Brown to don and doff the sanitary

and safety gear or equipment that she uses each workday.




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                                          Laronda Carruthers

        75.     Plaintiff Laronda Carruthers has been employed by Pilgrim’s Pride from April

1997 through the present at Pilgrim’s Pride’s Mayfield, Kentucky plant. She is a non-exempt

employee who works the day shift, which begins at 7 a.m.

        76.     To comply with Pilgrim’s requirements and to safely perform her job, Plaintiff

Carruthers is required to wear safety and sanitary gear and equipment including a smock, plastic

apron, mesh cutting gloves, rubber gloves, hard plastic arm guards, boots, hairnet, ear plugs and

bump cap before she begins work on the line.

        77.     Before reporting to her place on the line each day, Plaintiff Carruthers picks up

from the supply room required items of sanitary and safety equipment and gear, walks to her

locker where she obtains other items of sanitary and safety gear, puts on this gear and equipment,

walks to her department where she obtains from her supervisor mesh cutting gloves and hard

plastic arm guards, and puts on this equipment. She is not compensated for these activities,

which are integral and indispensable to Pilgrim’s Pride’s chicken processing business and related

to her principal employment duties.

        78.     Pilgrim’s Pride deducts thirty (30) minutes from Plaintiff Carruthers’ pay for an

unpaid lunch break each day. During this time, Ms. Carruthers must take off, put on, and clean

her protective gear and equipment. As a result, she spends considerable time during her unpaid

lunch break performing tasks that are integral and indispensable to Pilgrim’s Pride’s operations

and relate to her principal employment duties.

        79.     After completing her work on the chicken processing line, Plaintiff Carruthers is

required to take off, clean and store her protective gear and equipment. Ms. Carruthers is not




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compensated for any of these activities, which are integral and indispensable to Pilgrim’s

chicken processing business and related to her principal employment duties.

        80.     Plaintiff Carruthers works substantial time over 40 hours each work week for

which she is not compensated, either at a regular rate or at an overtime rate.

        81.     Pilgrim’s Pride requires or permits Plaintiff Carruthers to don and doff the

sanitary and safety gear or equipment that she uses each workday.

                                               Reneé Pates

        82.     Plaintiff Reneé Pates has been employed by Pilgrim’s Pride from July 1993-1999

and September 2000 to the present at the Farmerville, Louisiana plant. She currently works on

the 11:30 p.m. to 8:30 a.m. shift on the line in the bag half-leg quarters department.

        83.     To comply with Pilgrim’s requirements and to safely perform her job, Plaintiff

Pates is required to wear safety and sanitary gear and equipment including cotton gloves, rubber

gloves, plastic apron and sleeves, rubber boots, hairnet, and ear plugs.

        84.     Before reporting to her work station each day, Plaintiff Pates has to obtain and put

on her safety and sanitary gear and equipment, and walk to her place on the line. She is not

compensated for these activities, which are integral and indispensable to Pilgrim’s Pride’s

chicken processing business and related to her principal employment duties.

        85.     Pilgrim’s Pride deducts two thirty (30) minute unpaid breaks from Plaintiff Pates’

pay. During each unpaid break, Ms. Pates must take off, put on, and clean her protective gear

and equipment. As a result, Ms. Pates does not receive her full break as she spends considerable

time during her unpaid lunch break performing tasks that are integral and indispensable to

Pilgrim’s Pride’s operations and relate to her principal employment duties.




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        86.     After processing chickens at the end of her shift, Pates takes off and cleans her

protective gear and equipment. Pates is not compensated for these activities that are integral and

indispensable to Pilgrim’s Pride’s operations and relate to her principal employment duties.

        87.     Plaintiff Pates is compensated for approximately forty (40) hours of work per

week. However, she works substantial additional overtime hours each week for which she is not

compensated at either her regular rate or at an overtime rate.

        88.      Pilgrim’s Pride requires or permits Plaintiff Pates to don and doff the sanitary and

safety gear or equipment that she uses each workday.

                                             John Chambers

        89.     Plaintiff John Calvin Chambers was employed by Pilgrim’s Pride from March

2003 until March 2006 at the Marshville, North Carolina plant. Mr. Chambers worked as a non-

exempt employee on the 8:00 a.m. to approximately 5:00 p.m. shift on the assembly line in the

debone department.

        90.     To comply with Pilgrim’s Pride’s requirements and to safely perform his job,

Plaintiff Chambers was required to wear various safety and sanitary gear and equipment

including smock or coat, cotton gloves, rubber gloves, plastic apron, plastic sleeve covers,

hairnet, and ear plugs. Pilgrim’s Pride required that Chambers have on the protective gear and

equipment before he began work on the line.

        91.     Prior to start of his shift, Plaintiff Chambers had to obtain and put on his safety

and sanitary gear and equipment, and walk to his place on the line. Plaintiff Chambers was not

compensated for these activities, which were integral and indispensable to Pilgrim’s Pride’s

chicken processing business and related to his principal employment duties.

        92.     Pilgrim’s Pride deducted thirty (30) minutes from Mr. Chambers pay each day for

an unpaid lunch break. He was required to take off, put on, and clean his protective gear and


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equipment during his unpaid lunch break. As a result, Chambers spent considerable time during

his unpaid lunch break performing tasks that constitute work.

        93.     After completing his work on the chicken processing line, Plaintiff Chambers had

to remove, sanitize and store his protective gear and equipment. Mr. Chambers was not

compensated for any of these activities, which were integral and indispensable to Pilgrim’s

Pride’s chicken processing business and related to his principal employment duties.

        94.     Pilgrim’s Pride denied Plaintiff Chambers compensation at either his regular or

overtime rate for a substantial amount of time worked each week in excess of forty (40) hours of

work per week.

        95.     Pilgrim’s Pride required or permitted Plaintiff Chambers to don and doff the

sanitary and safety gear or equipment that he used each workday.

                                           Rose Mary Porter

        96.     Plaintiff Rose Mary Porter has been employed by Pilgrim’s Pride from October

28, 2002 through the present at the Chattanooga, Tennessee plant. Ms. Porter is a non-exempt

employee who works as a tender puller on the day shift on the line.

        97.     To comply with Pilgrim’s Pride’s requirements and to safely perform her job,

Plaintiff Porter is required to wear safety and sanitary gear and equipment including a smock,

rubber gloves, cloth gloves, ear plugs, plastic sleeves, and hair net.

        98.     Pilgrim’s Pride deducts thirty (30) minutes from Plaintiff Porter’s pay for at least

one unpaid break each day. Plaintiff Porter must take off, put on, and clean her protective gear

and equipment during her unpaid lunch break. As a result, Ms. Porter performs work during her

break that is integral and indispensable to Pilgrim’s Pride’s chicken processing business and

related to her principal employment duties, for which she is not compensated.




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         99.    After processing chickens, Plaintiff Porter takes off, cleans and stores her

protective gear and equipment. Porter is not compensated for any of these activities, which are

integral and indispensable to Pilgrim’s Pride’s chicken processing business and related to her

principal employment duties.

         100.   Plaintiff Porter is compensated for approximately forty (40) hours of work per

week. However, she actually works substantial additional hours each week for which she is not

compensated.

         101.   Pilgrim’s Pride requires or permits Plaintiff Porter to don and doff the sanitary

and safety gear or equipment that she uses each workday.

                                           LaShedria Traylor

         102.   Plaintiff LaShedria Traylor has been employed by Pilgrim’s Pride from December

21, 1994, through the present at the Mt. Pleasant, Texas plant. Traylor works on the 7:00 a.m. to

approximately 3:45 p.m. shift on the line as a bone checker in the debone department.

         103.   To comply with Pilgrim’s Prides’ requirements and to safely perform her job,

Plaintiff Traylor is required to wear safety and sanitary gear and equipment including cotton

gloves, steel gloves, rubber gloves, plastic apron and sleeves, rubber boots, hairnet, and ear

plugs.

         104.   Before reporting to her work station each day, Plaintiff Traylor has to obtain and

put on her safety and sanitary gear and equipment, and walk to her place on the line. Plaintiff

Traylor is not compensated for these activities, which are integral and indispensable to Pilgrim’s

Pride’s chicken processing business and related to her principal employment duties.

         105.   Pilgrim’s Pride deducts thirty (30) minutes from Plaintiff Traylor’s pay for an

unpaid lunch break each day. Plaintiff Traylor must take off, put on, and clean her protective

gear and equipment during her unpaid lunch break. As a result, Ms. Traylor performs work


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     Case 1:07-cv-01832-HFB              Document 21      Filed 07/20/2007       Page 20 of 25



during her break that is integral and indispensable to Pilgrim’s Pride’s chicken processing

business and related to her principal employment duties, for which she is not compensated.

          106.   After completing her work on the chicken processing line at the end of her shift,

Plaintiff Traylor is required to take off, clean and store her protective gear and equipment.

Plaintiff Traylor was not compensated for any of these activities, which are integral and

indispensable to Pilgrim’s chicken processing business and related to her principal employment

duties.

          107.   Plaintiff Traylor is compensated for approximately forty (40) hours of work per

week. However, she actually works substantial additional time each week for which she is not

compensated.

          108.   Pilgrim’s Pride requires or permits Plaintiff Traylor to don and doff the sanitary

and safety gear or equipment that she uses each workday.

                                               Melissa Hott

          109.   Plaintiff Melissa Hott was employed by Pilgrim’s Pride from 2002 until 2006 as a

non-exempt employee at the Moorefield, West Virginia plant. Ms. Hott most recently worked as

a Breader Operator on the chicken processing line, on the shift from 4:30 a.m. until

approximately 3:30 p.m., from 2004 to 2006.

          110.   To comply with Pilgrim’s Pride’s requirements and to safely perform her job, Ms.

Hott had to wear various safety and sanitary gear and equipment including, a smock, a plastic

apron, plastic sleeves, boots, plastic booties over boots, a hairnet, ear plugs, safety glasses, cotton

liner gloves, rubber gloves and mesh cutting gloves.

          111.   Before reporting to her work station each day, Ms. Hott had to obtain her safety

and sanitary gear and equipment from the supply room and her locker, assemble and put on all




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     Case 1:07-cv-01832-HFB              Document 21     Filed 07/20/2007      Page 21 of 25



gear and walk to her place on the line. Plaintiff Hott was not compensated for these activities,

which were integral and indispensable to Pilgrim’s Pride’s chicken processing business and

related to her principal employment duties.

        112.     Pilgrim’s Pride deducts a thirty (30) minute break from Plaintiff Hott’s pay each

day. Pilgrim’s Pride required Ms. Hott take off, put on, and clean items of protective gear and

equipment during her unpaid lunch break. As a result, she would not receive her full break, as

she was required to perform work during her break for which she was not compensated.

        113.    After completing her work on the chicken processing line at the end of her shift,

Ms. Hott was required to take off, clean and store her protective gear and equipment. She was

not compensated for any of these activities, which were integral and indispensable to Pilgrim’s

chicken processing business and related to her principal employment duties.

        114.    Ms. Hott worked over forty (40) hours of work per week. However, she worked

substantial additional overtime hours each week for which she was not compensated at either her

regular rate or at an overtime rate.

        115.    Pilgrim’s Pride required or permitted Plaintiff Hott to don and doff the sanitary

and safety gear or equipment that she used each workday.

                            COLLECTIVE ACTION ALLEGATIONS

        116.    Pursuant to 29 U.S.C. § 216(b), Plaintiffs bring this action on behalf of

themselves and the following similarly situated employees: current and former employees of

Pilgrim’s Pride who have held non-exempt positions working on or near the chicken processing

line in Pilgrim’s Pride chicken processing plants at any time during any part of the period from

April 20, 2003 through the date of notice in this action, who have not been fully compensated for

overtime hours worked.




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     Case 1:07-cv-01832-HFB              Document 21     Filed 07/20/2007        Page 22 of 25



        117.    Members of the proposed class are current or former Pilgrim’s Pride employees

who have been subject to the same unlawful practices alleged herein and, therefore, are similarly

situated to the Plaintiffs named in this Consolidated Complaint. The members of the proposed

class, like the Plaintiffs, work in jobs on or near the chicken processing line, and are subject to

the same or similar pay practices. All proposed class members, similar to the Plaintiffs, are

required to obtain, and don, required protective and sanitary gear, at the beginning of their

workday, and all proposed class members end their work day by doffing, cleaning and storing

that gear. Thus, the first and last compensable act of each workday is the same for these

proposed collective action members. Members of the proposed class and Plaintiffs, therefore,

should be permitted to pursue their claims collectively, pursuant to 29 U.S.C. § 216 (b).

        118.    Over 3000 current and former chicken processing workers from Pilgrim’s Pride’s

plants have already filed consents to participate in this action. Pursuit of this action collectively

will provide the most efficient mechanism for adjudicating the claims of the Plaintiffs and

members of the proposed class.

        119.    Plaintiffs Stephania Aaron, Alice Shepard, Dorothy Webb, Cynthia Rayborn,

Erica Gresham, Freida Brown, Laronda Carruthers, Reneé Pates, John Chambers, Rose Mary

Porter, LaShedria Traylor and Melissa Hott, request that they be permitted to serve as

representatives of those who have consented to participate in this action and that this action be

granted collective action status pursuant to 29 U.S.C. § 216(b).

                   VIOLATION OF THE FAIR LABOR STANDARDS ACT

        120.    Plaintiffs incorporate by reference all preceding paragraphs as if the same were

set forth again fully at this point.




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     Case 1:07-cv-01832-HFB              Document 21        Filed 07/20/2007       Page 23 of 25



        121.     Pilgrim’s Pride has willfully failed to pay Plaintiffs and members of the proposed

class at one and one-half times their regular rate for all hours worked in excess of 40 hours per

week, in violation of the Fair Labor Standards Act, as a result of which it owes them any and all

unpaid overtime wages incurred at any time since April 20, 2003, as well as liquidated damages.

        122.     Pilgrim’s Pride has willfully engaged in such conduct in violation of the Fair

Labor Standards Act by engaging in a pattern or practice of permitting or requiring Plaintiffs and

members of the proposed collective action to perform activities integral and indispensable to

their principal chicken processing activities, before and after the regular paid work time, and

during unpaid breaks without compensation at the applicable overtime rate for hours worked

over 40 per week.

                                            JURY DEMAND

        123.     Plaintiffs, individually and as representatives of the class, request a jury trial.

                                                PRAYER

        WHEREFORE, PREMISES CONSIDERED, Plaintiffs pray that the case be certified as a

collective action and that the Plaintiffs and each member of the class recover from Pilgrim’s

Pride, the following:

                 A.      An award of unpaid overtime in an amount appropriate to the proof at

        trial;

                 B.      An award of liquidated damages in an amount appropriate to the proof at

        trial;

                 C.      Court costs and costs of litigation, including expert fees;

                 D.      Attorneys’ fees; and

                 E.      Such other and further legal and equitable relief as the Court deems just.




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     Case 1:07-cv-01832-HFB              Document 21          Filed 07/20/2007     Page 24 of 25




Dated: July 20, 2007                                 Respectfully submitted,


/s/ Joseph M. Sellers                                Nick Patton
Joseph M. Sellers                                    Arkansas Bar #63034/
Jenny R. Yang                                        Kelly Tidwell
Cohen, Milstein, Hausfeld                            Arkansas Bar #88061
  & Toll, PLLC                                       Patton Tidwell & Schroeder, L.L.P.
1100 New York Avenue, NW                             4605 Texas Boulevard
Suite 500, West Tower                                P.O. Box 5398
Washington, DC 20005                                 Texarkana, Texas 75505-5398
(202) 408-4600                                       (903) 792-7080
(202) 408-4699 Facsimile                             (903)-792-8233 Facsimile
Counsel for Plaintiffs                               Counsel for Plaintiffs
Aaron v. Pilgrims Pride,1:06-CV-1082,                Aaron v. Pilgrims Pride, 1:06-CV-1082,
(W.D. Ark.)                                          (W.D. Ark.)
                                                     Antee v. Pilgrims Pride, 5:06-CV-0089,
                                                     (E.D. Tex.)

A. Craig Eiland                                      William S. Hommel
2423 Market Street, Suite #1                         Texas Bar No. 09934250
Galveston, TX 77550                                  1402 Rice Road
Texas Bar No. 06502380                               Suite 200
(409) 763-3260                                       Tyler, TX 75703
(409) 763-8154 Facsimile                             (903) 596-7100
Counsel for Plaintiffs                               (903) 792-8233
Aaron v. Pilgrims Pride, 1:06-CV-1082,               Counsel for Plaintiffs
(W.D. Ark.)                                          Aaron v. Pilgrims Pride, 1:06-CV-1082,
Antee v. Pilgrims Pride, 5:06-CV-0089,               (W.D. Ark.)
(E.D. Tex.)                                          Antee v. Pilgrims Pride, 5:06-CV-0089,
                                                     (E.D. Tex.)

George Chandler                                      Philip R. Russ
Kirk Mathis                                          2700 South Western #1200
Law Offices of George Chandler                       Amarillo, Texas 79109
P.O. Box 340                                         (806) 358-9293
Lufkin, TX 75902-0340                                (806)358-9296 Facsimile
(936) 632-7778                                       Counsel for Plaintiffs
(936) 632-1304 Facsimile                             Aaron v. Pilgrims Pride, 1:06-CV-1082,
Counsel for Plaintiffs                               (W.D. Ark.)
Aaron v. Pilgrims Pride, 1:06-CV-1082,               Antee v. Pilgrims Pride, 5:06-CV-0089,
(W.D. Ark.)                                          (E.D. Tex.)
Antee v. Pilgrims Pride, 5:06-CV-0089,
(E.D. Tex.)



Plaintiffs’ Consolidated Complaint - Page 24 of 24
     Case 1:07-cv-01832-HFB          Document 21      Filed 07/20/2007     Page 25 of 25




      Robert L. Salim                             Robert Camp
      1762 Texas St                               Cochran Firm, P.C.
      Natchitoches, LA 71457                      505 N. 20th Street
      (318) 352-5999                              Suite 825
      (318) 352-0303 Facsimile                    Birmingham, AL 35203
      Counsel For Plaintiffs in                   Counsel for Plaintiffs in
      Aaron v. Pilgrims Pride, 1:06-CV-1082,      Benford v. Pilgrims Pride, 1:07-CV-
      (W.D. Ark.)                                 1041
      Antee v. Pilgrims Pride, 5:06-CV-0089,      (N.D. Ala.)
      (E.D. Tex.)

     Peter H. Burke                               Preyesh Maniklal
     William Todd Harvey                          Tisha R. Tallman
     Burke, Harvey & Frankowski, LLC              Gregory, Christy, Maniklal & Dennis,
     2151 Highland Ave.                           LLP
     Suite 120                                    4360 Chambelle Dunwoody Road
     Birmingham, AL 35205                         Suite 428
     205-930-9091                                 Atlanta, GA 30341
     Counsel for Plaintiffs in                    Counsel for Plaintiffs in
     Aguilar v. Pilgrims Pride, No. 5:06-1673     Brown v. Pilgrim’s Pride, No. 3:07-CV-
     (N.D. Ala.)                                  0024 (M.D. Ga.)
     Hernandez v. Pilgrims Pride, No. 07-CV-
     00020 (N.D. Ga.).

     David W. Garrison                            David Moskowitz
     Barrett, Johnston & Parsley                  Deirdre Morgan
     217 Second Avenue North                      Morgan & Morgan
     Nashville, TN 37201                          191 Peachtree Street, NE
     615.244.2202 – phone                         Suite 4200
     615.252.3798 – fax                           Atlanta, GA 30303
     Counsel for Plaintiffs in                    (877) 989-9990
     Porter v. Pilgrims Pride, No. 06-CV-259      (404) 965-8812 Facsimile)
     (E.D. Tenn.)                                 Counsel for Plaintiff in
     Menser v. Pilgrims Pride, No. 07-CV-         Hernandez v. Pilgrims Pride, No. 07-CV-
     00029 (W.D. Ky.)                             00020 (N.D. Ga.).


     Richard Celler
     Morgan & Morgan
     284 South University Drive
     Fort Lauderdale, FL 33324
     877-435-9243 – phone
     954-333-3515 – fax
     Counsel for Plaintiff in Allen v. Pilgrims
     Pride , No. 3:07-cv-00019-CDL (M.D.
     Ga.)

Plaintiffs’ Consolidated Complaint